Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Safe harbour eligible assessee rules define qualifying service providers, intra-group financing, guarantees, and low-risk research arrangements. Eligible assessee status under the safe harbour rules is available only to a person who has exercised a valid option under rule 10TE and falls within specified categories, including software development, IT enabled services, KPO, intra-group loans, corporate guarantees, specified contract research and development, auto component manufacturing and export, and low value-adding intra-group services. For software and research services, the foreign principal must perform the economically significant functions, provide capital, intangibles and supervision, bear the realised risks, and retain ownership of the intangible or research outcome; contractual terms are not conclusive if conduct shows otherwise.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Safe harbour eligible assessee rules define qualifying service providers, intra-group financing, guarantees, and low-risk research arrangements.
Eligible assessee status under the safe harbour rules is available only to a person who has exercised a valid option under rule 10TE and falls within specified categories, including software development, IT enabled services, KPO, intra-group loans, corporate guarantees, specified contract research and development, auto component manufacturing and export, and low value-adding intra-group services. For software and research services, the foreign principal must perform the economically significant functions, provide capital, intangibles and supervision, bear the realised risks, and retain ownership of the intangible or research outcome; contractual terms are not conclusive if conduct shows otherwise.
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